Scheffer v. Railroad Co.
1881 U.S. LEXIS 2114, 105 U.S. 249, 26 L. Ed. 1070 (1882)
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Rule of Law:
For an act of negligence to be considered the proximate cause of an injury, the injury must be the natural and probable consequence of the negligence, and it must have been foreseeable under the circumstances; an intervening act of self-destruction is generally considered too remote if it was not a foreseeable consequence of the initial injury.
Facts:
- On December 7, 1874, a collision occurred between trains on the Washington City, Virginia Midland, and Great Southern Railroad due to the company's negligence.
- Charles Scheffer was a passenger on one of the trains and was severely cut, bruised, maimed, and injured about his head, face, neck, back, and spine.
- As a result of these injuries, Charles Scheffer became sick, sore, lame, and disordered in mind and body, developing 'phantasms, illusions, and forebodings of unendurable evils to come upon him'.
- This mental disease continued to disturb, harass, annoy, and prostrate his nervous system, baffling all medical skill.
- On August 8, 1875, approximately eight months after the collision, these 'phantasms, illusions, and forebodings' overcame Charles Scheffer's reasoning powers, inducing him to take his own life.
- Charles Scheffer died by suicide, leaving a wife and children surviving him.
Procedural Posture:
- The executors of Charles Scheffer sued the Washington City, Virginia Midland, and Great Southern Railroad Company in a Circuit Court (a trial court), seeking damages for his death.
- The Railroad Company filed a demurrer to the executors' declaration, essentially arguing that even if the facts alleged were true, they did not establish a legal claim for which the company could be held responsible.
- The Circuit Court sustained the demurrer, ruling that Charles Scheffer's death was not due to the company's negligence in a judicial sense, as the proximate cause was the decedent's suicide.
- The executors, as appellants, filed a writ of error to appeal the judgment of the Circuit Court to the Supreme Court of the United States.
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Issue:
Does a railroad company's negligence in causing a train collision constitute the proximate cause of a passenger's death by suicide, where the suicide occurred eight months after the injury and was preceded by mental aberration resulting from the injury?
Opinions:
Majority - Mr. Justice Miller
No, the railroad company's negligence was not the proximate cause of Charles Scheffer's death by suicide. The Court concurred with the Circuit Court's finding that the death was too remote from the initial negligence. The suicide was a new and sufficient cause of death, intervening between the original injury and the ultimate demise. Drawing on precedents like Insurance Company v. Tweed and Milwaukee & St. Paul Railway Co. v. Kellogg, the Court reasoned that to establish proximate cause, the injury must be a natural and probable consequence of the negligence and ought to have been foreseen under the circumstances. The Court found that Scheffer’s suicide was not a natural and reasonably expected result of the train injury, nor was his resulting insanity. Both his insanity and subsequent suicide were deemed casual or unexpected causes, making the railroad's initial negligence too remote to establish liability for his death.
Analysis:
This case is foundational in establishing limitations on liability for remote consequences in tort law, particularly concerning intervening acts. It reinforces the principle that liability for negligence does not extend indefinitely, especially when a 'new cause' breaks the chain of causation. The Court's emphasis on foreseeability and 'natural and probable consequence' has had a lasting impact on how courts determine proximate cause, making it harder for plaintiffs to recover for injuries that are highly unusual or unexpected, even if medically linked to an initial negligent act. This decision has been influential in cases involving suicide following personal injury, generally requiring a very direct and foreseeable link between the tortious act and the self-harm for liability to attach.
